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510(k) Data Aggregation
(29 days)
ProSeal Bag Spike with Additive Port (423370ST, 423370)
The ProSeal™ CSTD mechanically prohibits environmental contaminants from entering the system and the escape of drug or vapor concentrations from the system, thereby minimizing individual and environmental exposure to drug vapor, aerosols, and spills. The ProSeal™ system also prevents the introduction of microbial contaminations into the drug or fluid path for up to 7 days when used as intended.
The ProSeal™ Bag Spike with Additive Port (or "and Seal Tab" (suffixed ST model no.)) serves as an adaptor between I.V. bags and ProSeal™ CSTD components, facilitating closed system fluid transfer. The spiking port of this device is compatible with generic I.V. spikes. Additionally, the additive port (injection site) allows medication to be added to the bag using the cleared ProSeal™ Injector or Injector Plus (both Syringe Adaptors).
The injection site of the ProSeal™ Bag Spike with Additive Port (or "and Seal Tab") and all corresponding interface membranes ensure a dry connection during fluid transfer. Utilizing this component and its appropriate ProSeal™ CSTD connecting component reduces the risk of microbial ingress for up to 168 hours (7 days).
This document describes a 510(k) clearance for a medical device called "ProSeal™ Bag Spike with Additive Port." 510(k) clearances are for medical devices that are substantially equivalent to a legally marketed predicate device. This process primarily relies on demonstrating that the new device has the same intended use and similar technological characteristics, and that any differences do not raise new questions of safety or effectiveness.
Important Note: The provided FDA 510(k) clearance letter and summary do not describe a study involving a medical device with Artificial Intelligence (AI) or machine learning (ML) capabilities. The document pertains to a physical medical device (an intravascular administration set) and its mechanical and material properties. Therefore, the questions related to AI/ML specific criteria (e.g., sample size for training set, number of experts for ground truth, MRMC studies, AI assistance) are not applicable to this specific clearance.
I will focus on the acceptance criteria and performance data provided for this physical medical device.
Acceptance Criteria and Device Performance for ProSeal™ Bag Spike with Additive Port
Since this 510(k) is for a physical medical device and not an AI/ML device, the "acceptance criteria" are based on meeting established national and international standards for medical device safety and performance, as well as demonstrating substantial equivalence to a predicate device.
1. Table of Acceptance Criteria and the Reported Device Performance
The device performance is demonstrated by conformance to various ISO standards and validation testing. The table below summarizes the key performance areas and the general nature of the reported performance, as specific quantitative acceptance criteria or detailed results are not explicitly listed in this type of summary document, but rather conformance to the standards is stated.
Acceptance Criterion (Standard/Test) | General Performance Reported |
---|---|
Functional Performance | |
Leak integrity test (ISO 8536-4:2019, 7.2 & Annex A.3) | Met standard requirements. |
Tensile strength test (ISO 8536-4:2019, 7.3 & Annex A.4) | Met standard requirements. |
Flow rate test (ISO 8536-4:2019, Annex A.5.1) | Met standard requirements. |
Protective caps test (ISO 8536-4:2019, 7.13) | Met standard requirements. |
IV Bag Spike penetration force test (ISO 22413:2021, Annex A.7) | Met standard requirements. |
Spiking port penetration ability (K223674) | Met standard requirements. |
Spiking port adhesion strength (K223674) | Met standard requirements. |
Impermeability to microorganism (ISO 15747:2018, Annex C.2) (7-days) | Prevents microbial ingress for up to 7 days. |
Vapor containment test (NIOSH CSTD 2016 draft protocol) | Successfully contains drug vapor/aerosols/spills. |
Microbial ingress test (FDA guidance & ANSI AAMI CN27:2021) (7-days) | Prevents microbial ingress for up to 7 days. |
Biocompatibility (ISO 10993 series) | Acceptable biological risks established. |
Cytotoxicity, Sensitization, Intracutaneous reactivity, Acute systemic toxicity, 14-day subacute/subchronic systemic toxicity, In-vitro hemolysis, Material mediated pyrogenicity | All tests performed on component materials, demonstrating acceptable biocompatibility. |
Chemical characterization & toxicological risk management (ISO 10993-18, -17) | Acceptable chemical properties and risk profile. |
Chemical requirements testing (ISO15747:2018, Annex B) | Met standard requirements. |
Particulate matter analysis (ISO 8536-4:2019, USP ) | Met standard requirements for particulate matter. |
Sterility (ISO 11135:2014) | Complies with sterilization requirements (SAL 10⁻⁶). |
Pyrogen tests (ANSI/AAMI ST72/2019, USP standards) | Met pyrogenicity requirements. |
Shipping & Shelf-Life | |
Simulated shipping testing (ASTM D 4169-16) | Met standard requirements. |
Package integrity tests (ASTM F1980-21, ASTM F88/F88M-21, ASTM F1929-23, EN 868-5:2009) | Met standard requirements for package integrity. |
Shelf-life validation (ASTM 1980-21) | Validated for 3 years (36 months). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify the exact sample sizes used for each individual functional, biocompatibility, sterility, shipping, or shelf-life test. This level of detail is typically found in the full test reports, not in the 510(k) summary. For device clearances, compliance is often demonstrated by testing a statistically significant number of units to ensure performance within specifications, but the exact number isn't usually summarized here.
- Data Provenance: The document does not explicitly state the country of origin of the data. However, the submitter is Epic Medical Pte. Ltd. based in Singapore, suggesting the testing could have been conducted there or by affiliated labs. The testing refers to "bench performance verifications and validations" and "existing 510(k) cleared referred-to devices (K222929, K223674, K241988)" for leveraging data. This indicates the data is retrospective, drawing from previous tests on related and cleared devices, as well as specific new tests for the subject device. There is no indication of prospective clinical studies.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
- Not Applicable: This criterion relates to AI/ML model validation, where human experts (e.g., radiologists) establish ground truth for image interpretation. For a physical medical device like an intravascular administration set, "ground truth" is established through engineering and biological testing against predefined performance standards and specifications, not through expert consensus on qualitative data. The "experts" would be the engineers, microbiologists, and other scientific and quality control personnel conducting the rigorous lab tests and validations.
4. Adjudication Method for the Test Set
- Not Applicable: Adjudication methods (e.g., 2+1, 3+1) are typically used in clinical studies or AI/ML model validation to resolve discrepancies in expert interpretations of data. For a physical device, performance is objectively measured against quantifiable technical specifications and standards (e.g., no leaks observed, flow rate within X range, microbial ingress count below threshold).
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not Applicable: MRMC studies are specific to evaluating the diagnostic performance of AI-assisted systems where human readers interpret medical images or data. This device is a physical product, not an AI system.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Not Applicable: This criterion is for AI/ML algorithms. The performance of this device is inherently its standalone physical function.
7. The Type of Ground Truth Used
- Objective Test Results / Conformance to Standards: The "ground truth" for this device's performance is established by objective engineering measurements, chemical analyses, and biological assays that demonstrate compliance with recognized industry standards (ISO, ASTM, ANSI, USP) and the device's design specifications. Examples include:
- Absence of leaks under specified pressure.
- Maintaining sterility and preventing microbial ingress for 7 days.
- Meeting pre-defined flow rates.
- No evidence of cytotoxicity, sensitization, or pyrogenicity in biocompatibility tests.
- Successful vapor containment.
8. The Sample Size for the Training Set
- Not Applicable: There is no "training set" in the context of a physical medical device. This term applies to machine learning models.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable: As there is no training set for a physical device, this question is not relevant.
Summary of Study that Proves the Device Meets Acceptance Criteria for this Physical Device:
The study proving the device meets acceptance criteria is a comprehensive set of bench performance verifications and validations, along with biocompatibility, sterility, shipping, and shelf-life testing.
- Purpose: To demonstrate that the ProSeal™ Bag Spike with Additive Port is safe and effective for its intended use as an intravascular administration set component, and that any differences from its predicate device (ProSeal™ Closed System Bag Access, K241988) do not raise new questions of safety or effectiveness.
- Methodology:
- Functional Testing: The device was subjected to various mechanical and functional tests based on ISO standards (e.g., ISO 8536-4, ISO 22413, ISO 15747, ANSI AAMI CN27), including leak integrity, tensile strength, flow rate, protective cap strength, IV bag spike penetration force, and impermeability to microorganisms (demonstrated for 7 days). Vapor containment was also assessed using a NIOSH CSTD draft protocol.
- Biocompatibility Testing: In accordance with ISO 10993-1:2018 for externally communicating devices (blood path indirect, prolonged contact), various biocompatibility tests were performed on the device's materials, leveraging data from previously cleared predicate and similar devices (K222929, K223674, K241988). These included cytotoxicity, sensitization, systemic toxicity, hemolysis, pyrogenicity, chemical characterization, and particulate matter analysis.
- Sterility Validation: Compliance with ISO 11135:2014 for Ethylene Oxide sterilization (SAL 10⁻⁶) was demonstrated, along with pyrogen testing.
- Shipping and Shelf-Life Validation: Simulated shipping (ASTM D 4169-16) and package integrity tests (ASTM F1980-21, ASTM F88/F88M-21, ASTM F1929-23, EN 868-5:2009) were conducted. Shelf-life of 3 years was validated using accelerated aging (ASTM 1980-21).
- Data Sourcing: Data was obtained from new tests performed on the subject device and by leveraging data from previously cleared devices (K222929, K223674, K241988) that share similar components or materials, indicating a retrospective data approach for certain aspects.
- Conclusion: The results of these tests and validations confirmed that the subject device meets all relevant performance standards and does not raise new questions of safety or effectiveness compared to the predicate device, thus demonstrating substantial equivalence.
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